Published works by Erin K. Sullivan

Published works

• DOJ Announces Record Number of Defendants Charged in 2026 National Health Care Fraud Takedown

  Eye on Enforcement · July 1, 2026

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• States Sue to Block Agencies from Adding Anti-DEI Clauses to Government Contracts

  Eye on Enforcement · June 24, 2026

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• Does Your Company Use Data Analytics in Its Anti-corruption Program? It Should

  Eye on Enforcement · May 22, 2024

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• The Zero-Point Offender Adjustment: U.S. Sentencing Commission’s Proposed Amendment Gives Some First-Time Offenders a Break

  Eye on Enforcement · August 9, 2023

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• Government Contractor Booz Allen Hamilton Enters One of the Largest Procurement Fraud Settlements with DOJ over FCA Allegations

  Eye on Enforcement · August 2, 2023

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• Beneficial Ownership Reporting: Questions Over Meaning of “Substantial Control”

  Eye on Enforcement · February 9, 2023

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• DOJ Expands Availability of Declinations with Disgorgement for Corporations that Self-Disclose Misconduct

  Eye on Enforcement · January 30, 2023

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• Supreme Court to Consider False Claims Act “Objectively Reasonable” Knowledge Standard

  Eye on Enforcement · January 24, 2023

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• Eighth Circuit Requires “But-For” Causation in FCA Cases Based on Anti-Kickback Statute

  Eye on Enforcement · October 5, 2022

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• Facilitating Ransomware Payments Entails Sanctions Risks, OFAC Warns

  Financial Services Perspectives · October 2, 2020

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• DOJ Tells Investment Adviser that Payment to Foreign Government-Owned Bank Will Not Prompt FCPA Enforcement Action

  Financial Services Perspectives · August 20, 2020

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• DOJ’s FCPA Corporate Enforcement Policy Creates Greater Certainty for Companies

  Financial Services Perspectives · December 6, 2017

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